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an addition to tax under section 6651(a) for failure to file a
timely return in 1991; and (7) whether petitioner is liable for
negligence penalties under section 6662(a) for the years 1990 and
1991.
For the purposes of convenience, we have combined the
findings of fact and discussion of pertinent legal issues. Some
of the facts have been stipulated, and they are so found. The
stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time of filing the petitions,
petitioner resided in Berkeley, California.
We begin by noting that respondent's determinations are
presumed correct, and petitioner bears the burden of proving that
those determinations are erroneous. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are a
matter of legislative grace, and petitioner bears the burden of
proving that he is entitled to any deductions claimed. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Dependency Exemptions in 1990 and 1991
Petitioner is single, having been divorced from his former
wife in 1972, and his daughter, Jacqueline, resided with him in
1990. Jacqueline was born on April 10, 1966. Petitioner's
mother, Laverne Baker (Ms. Baker), resided with petitioner from
January 1 to September 1, 1991. Ms. Baker, 80 years old during
that year, was blind and suffered from Alzheimer's disease. Ms.
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